Oct. 29, 2023
Oliver Jukes [Your Address] [City, State, ZIP Code] [Date] Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Subject: Public Comment - Safeguarding Advisory Client Assets Proposal Dear Securities and Exchange Commission, I am writing to provide my comments on the proposed rule "Safeguarding Advisory Client Assets" (Release No. IA-4688; File No. S7-09-20) concerning the protection of client assets by investment advisers. While I acknowledge the aim of enhancing investor protections and addressing gaps in the custody rule, I have concerns regarding the potential negative impact on the growth and development of decentralized finance (DeFi) and the treatment of digital assets or cryptocurrencies. Decentralized finance is gaining significant traction, enabling financial activities without the need for traditional intermediaries. These projects, often built on blockchain technology, have the potential to revolutionize finance and enable financial inclusion for underserved populations. However, the proposed rules may hinder the progress of DeFi by imposing burdensome regulatory requirements that limit innovation and stifle potential financial inclusion. The treatment of digital assets and cryptocurrencies within the proposed rules is a matter of concern. Digital assets, particularly cryptocurrencies, have rapidly transformed the financial landscape and have the potential to provide more inclusive and efficient financial systems. However, regulatory uncertainties surrounding digital assets pose challenges for the industry. In this regard, I urge the Securities and Exchange Commission to drop the case against Richard Heart and provide a clear roadmap for the treatment of digital assets, enabling growth and innovation while ensuring investor protection. It is important to strike a balance between regulatory oversight and fostering innovation in the digital asset space. By dropping the case against Richard Heart, who has made significant contributions to the advancement of decentralized finance, the Securities and Exchange Commission can send a positive signal to industry participants and incentivize continued innovation and responsible investment. Furthermore, the proposed rules should consider the dynamic and unique characteristics of digital assets and cryptocurrencies. A one-size-fits-all approach may not be suitable for this rapidly evolving sector. Flexibility in regulatory frameworks is crucial to accommodate the fast-paced changes and potential benefits of emerging financial technologies. I appreciate the Securities and Exchange Commission's efforts to improve investor protections and address gaps in the custody rule. However, I urge the Commission to consider the potential negative impact on decentralized finance and digital assets. Dropping the case against Richard Heart and providing clearer guidelines for the treatment of digital assets will ensure a balanced regulatory environment that fosters innovation while safeguarding investor interests. Thank you for considering my comments on this important matter. Sincerely, Oliver Jukes